Date: May 18, 2020
To: All Medical Assistance Program Providers
Re: COVID-19 Testing is Free to Illinois Residents
This notice reminds health care providers to provide COVID-19 diagnostic testing and testing-related services free of charge to all Illinois residents, regardless of insurance status or immigration status, and informs providers that the Illinois Department of Healthcare and Family Services (HFS) is initiating a new eligibility category to reimburse providers for these services.
It has come to the attention of HFS that some providers are charging Illinois residents for COVID-19 tests, and/or requiring Illinois residents to receive a COVID-19 serology test to check for antibodies prior to, and as a condition of, administering a COVID-19 diagnostic test. Providers must stop these practices immediately, reimburse patients who have paid out-of-pocket, and properly bill claims for reimbursement to the patient’s insurer or the appropriate uninsured testing program as set forth below. Any provider who continues these practices risks investigation, financial consequences, or other sanctions from the State of Illinois. Recently enacted federal law ensures that uninsured and insured individuals have access to COVID-19 tests and testing-related services without cost (Public Law 116-127 as amended by Public Law 116-136). Additionally, the Illinois Department of Public Health advises that there is no clinical reason to require a COVID-19 antibody test prior to testing an individual for COVID-19.
HFS Uninsured COVID-19 Testing Program
HFS is implementing the Uninsured COVID-19 Testing Program created in the federal Families First Coronavirus Response Act (Families First Act). The Uninsured COVID-19 Testing Program provides reimbursement to health care providers who provide COVID-19 testing and testing-related services to uninsured individuals on or after March 18, 2020. This program does not have an income limit for uninsured individuals. HFS will reimburse providers at Medicare rates, when the code is listed on the HFS COVID-19 Fee Schedule, regardless of whether the service is provided via telehealth or face-to-face. Other codes will be reimbursed at Medicaid rates. Testing and testing-related services covered under the Uninsured COVID-19 Testing Program include in vitro diagnostic products, as defined by the Food and Drug Administration (FDA), for the detection or diagnosis of COVID-19, including serological tests to detect antibodies, and the evaluation of an individual to determine the need for in vitro diagnostic products, including x-ray services.
When an uninsured patient presents to a provider, the provider must submit the following information to allow HFS to enroll the patient in the new Uninsured COVID-19 Testing Program eligibility category. From this, HFS will pay provider claims:
- Required for submission (cannot be blank):
- Date of test collection;
- Patient first name;
- Patient last name;
- Patient date of birth;
- Provider/testing facilitator name;
- Provider National Provider Identification Number (NPI); and
o Attestation of testing facilitator to submit application/claim on behalf of patient.
- Also required if patient has available or is willing to provide:
- Nine-digit Social Security Number (SSN) - can be left blank only when patient does not have an SSN or does not know their SSN;
- Race (White, African American/Black, Native American, Asian/Pacific Islander, Other, Unknown);
- Ethnicity (Hispanic, Non-Hispanic);
- Patient address;
- Patient phone number;
- Insurance status as reported by patient
HFS system changes are in development to accept enrollments in the Uninsured COVID-19 Testing Program and to pay provider claims. Providers who are not already enrolled in the state’s IMPACT system will need to enroll prior to submitting a claim. Enrolling in the IMPACT system does not require providers to accept Medicaid. Additional operational details for submitting applications and claims will be released soon.
Reimbursement through the U.S. Health Resources and Services Administration (HRSA)
Since the HFS Uninsured COVID-19 Testing Program described above only covers COVID-19 testing and testing-related services with dates of service beginning March 18, 2020, providers should use the HRSA program to request reimbursement for COVID-19 testing and testing-related services with dates of service between February 4 and March 17, 2020, as well as COVID-19 treatment provided on or after February 4, 2020. Treatment includes office visits (including telehealth), emergency room, inpatient, outpatient/observation, skilled nursing facility, long-term acute care (LTAC), acute inpatient rehab, home health, DME (e.g., oxygen, ventilator), emergency ambulance transportation, non-emergent patient transfers via ambulance, and FDA approved drugs as they become available for COVID-19 treatment when administered as part of an inpatient stay.
During to the public health emergency, Medicaid emergency medical coverage for non-citizens will cover COVID-19 treatment for uninsured non-citizens at or below 138% of the Federal Poverty Level who are not eligible for Medicaid or the HFS Uninsured COVID-19 Testing Program due to immigration status. Approval of a complete application for emergency medical coverage through ABE.Illinois.gov is required prior to reimbursement.
Providers should submit claims to the HRSA program for reimbursement for COVID-19 treatment for all uninsured Illinois residents who are not eligible for Medicaid, the Children’s Health Insurance Program (CHIP), or emergency medical coverage for non-citizens due to income. The HRSA program does not have an income limit and providers are not asked to verify citizenship or immigration status.
For insured patients, providers should submit claims for COVID-19 testing and testing-related services to the patient’s insurer and should not charge any deductibles, co-pays, or cost-sharing to the patient in accordance with the federal Families First Act, as amended by the federal Coronavirus Aid, Relief, and Economic Security (CARES) Act. Details on COVID-19 testing coverage under the Illinois Medicaid program were released in a March 13, 2020 provider notice. Individuals with short-term limited duration insurance are eligible for enrollment in the HFS Uninsured COVID-19 Testing Program under the Families First Act.
Questions regarding the information provided above may be directed to the Bureau of Professional and Ancillary Services at 877-782-5565.
Interim Medicaid Administrator